Comment Analysis · Docket FS-2025-0001

FS-2025-0001-280187

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted August 28, 2026 On Regulations.gov

In short: The comment establishes that rescinding the Roadless Rule would expose the Reservoir in the Wallowa-Whitman National Forest to road construction and ground disturbance, citing scientific evidence that such roads degrade drinking water supplies and aquatic habitat, and asserting that the proposed rescission conflicts with the rule's purposes and legitimate reliance interests.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

  • Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
  • Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
  • EA analysisEngages the agency's environmental analysis directly.
  • Analytical gapIdentifies something the analysis fails to address.
  • EvidenceBacks claims with specific facts, data, or research.
  • RequestMakes a specific, actionable request of the agency.
  • AlternativeProposes a different course of action.
  • LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A3 weak: Substantive, but easier to set aside.

Owed an answer on Evidence.

Standard dismissals it defeats

  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

Still open to the agency

  • Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
  • Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
  • Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
  • Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
  • Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
  • No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
  • Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Topics

  • Water Quality Quantity
    • “source of our drinking water and water for our farms and livestock”
    • “Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies”
    • “harming local water quality”
    • “Road impacts on hydrology persist for decades after roads stop being used”
  • Environmental Protection Biodiversity
    • “degrade drinking-water supplies and aquatic habitat downstream”
    • “increase the risk of landslides”
    • “Roadless Rule protects our community more than any other government function”
  • Recreation Tourism Public Use
    • “enjoy the hiking and hunting and fishing available to us on these lands”
    • “most of my favorite memories of living here involve many of the roadless areas”
    • “horse-logging some dead trees out of a campground”
  • Economic Impact Fiscal
    • “roads that would have to be constructed would be expensive to build and maintain”
    • “Changing the Roadless Rule would cost money we don't have”
    • “trees never reach a size or height that would offer commercial value”

What it names

National Forests
Wallowa-Whitman National Forest
Works cited
10.1016/j.jenvman.2009.01.014

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Legal

To the U.S. Forest Service Roadless Rule Docket: Living in a rural county where the federal forest is the de facto water tower, I think about the roadless rule the way I think about the roof on my barn — you notice it most when it fails. The many National Forests and other public lands around my community are the lifeblood of the community, the source of our drinking water and water for our farms and livestock. Many of us also enjoy the hiking and hunting and fishing available to us on these lands. The Roadless Rule protects our community more than any other government function ever possibly could. One occasion in particular illustrates what that relationship means in practice. We work or go to school in town, but it's out in the roadless areas around us that we truly live - most of my favorite memories of living here involve many of the roadless areas, like horse-logging some dead trees out of a campground one winter, avoiding the need for roads. The proposed rescission cannot be squared with the purposes served by the Rule or with the legitimate reliance interests it has generated over nearly twenty-five years of implementation. Regarding the Reservoir in the Wallowa-Whitman National Forest, Oregon: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Persistence after abandonment. Road impacts on hydrology persist for decades after roads stop being used. Forest roads in northern Idaho abandoned for 30–50 years still showed an order of magnitude lower saturated hydraulic conductivity than undisturbed forest floor (Foltz et al. 2009; Trombulak & Frissell 2000). — R. B. Foltz, N. S. Copeland, W. J. Elliot, 2009 · Journal of Environmental Management (https://doi.org/10.1016/j.jenvman.2009.01.014) Rescinding the Roadless Rule would open the Reservoir, Wallowa-Whitman National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. The roadless areas around my community are on steep land, hot and dry in the summer and buried in deep snow in winter. The roads that would have to be constructed would be expensive to build and maintain and would immediately increase the risk of landslides, while also harming local water quality, and any roads would offer virtually no value, even for logging - we have hard winters, and most trees never reach a size or height that would offer commercial value. Changing the Roadless Rule would cost money we don't have while creating bigger problems we're already trying to avoid. This rulemaking should conclude with the 2001 Rule intact. With hope, CommentID: RLC-20260827-5LX82S

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